During one of our recent exams, it was suggested by the examiners that we open accounts online (which surprised us); they would like us to phase out our brokered deposits and felt we could replace these deposits by opening accounts online. I have been trying to gather some information on what is involved in opening accounts online, in particular the risks involved; how to handle CIP, how to handle disclosures and how to obtain the initial deposit. I put out a question on Banker Threads, but did not receive much information. Can you direct me to any information that would help?Also, our president would like me to do a comparison to Free Checking - the pros and cons vs online accounts. While I have not experienced opening accounts online, I have been at a bank (some years ago) that offered free checking and we had a good experience. Few losses, customers really liked not having to worry about a maintenance fee, and the average balance tended to be around $3,000. I was wondering if you could direct me to any other sources that might be able to provide information or statistics on free checking?

My question is related to PART 205—ELECTRONIC FUND TRANSFERS (REGULATION E) Section 205.17 Requirements for overdraft services. <i>(iv) Provides the consumer with confirmation of the consumer's consent in writing, or if the consumer agrees, electronically, which includes a statement informing the consumer of the right to revoke such consent.</i> For new accounts, will this requirement for confirmation be satisfied if the new account disclosures contain the appropriate language, or are we required to mail a separate confirmation to the customer who opts in after the fact?

When we open new accounts, we like having customers sign up for online banking at that time. Marketing created a form where the customer waives the requirements for demonstrable consent and certifies they meet the hardware and software requirements we have to get our e-statements. Is this satisfactory?

We are a small three branch bank. Our CEO is pressuring the staff to open new checking/savings accounts online at our website. I have been to numerous banking seminars, and from what I understand, banks that currently are opening up new accounts on their websites are suffering substantial losses. What can we do to prevent this from happening at our institution in the event we decide to open new accounts on the Web? And can we restrict the opening of new accounts to residents of our state only?

Asking this question for both current and future rules:
On a construction-permanent loan application that has only one closing and one set of LE/CD disclosures for the transaction, what should the "sale price" be on the LE/CD with a transaction that involves a seller?
Should it only be the amount of the purchase price or should the cost to construct be included with the purchase price? I'm leaning towards the purchase price only based on 1026.37(a)(7) but we've been adding in the construction costs for some time now without criticism...

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